Documenting Safe Procedures

Basic requirements for evaluating chemical hazards and selecting protective measures are the same whether an employee manipulates chemicals in a chemical laboratory, or if the employee uses chemicals in a shop or other non-chemical-lab location. However, different regulations require somewhat different formats for documenting the assessment. Work situations that may need to be assessed fall into five main categories:

  • Routine tasks in a chemical laboratory,
  • Routine tasks in a shop, non-chemical lab or other work area,
  • New or infrequently performed tasks,
  • Re-assessment after an accident or incident, and
  • Situations that could impact anyone.

Assessing Routine Tasks in a Chemical Laboratory

Assuming that you are evaluating a procedure which has been done before in your laboratory or another lab where you have access to a complete description of the procedures (if a new procedure, see the new procedure sub-section below), you should:

  • Identify the procedure and the chemicals and equipment involved,
  • Based on the chemicals and processes to be used, list all the hazards that are associated with the particular procedure (a way of categorizing hazards is shown in the HazCom Training Categories document (pdf)),
  • Identify the precautions, safety equipment, and personal protective equipment used, being as specific as possible, As part of this assessment, assess whether a less hazardous chemical can be used or if a lesser amount of the chemical can be used to accomplish the task.
  • Describe spill cleanup procedures and waste disposal procedures,
  • Identify any authorizations needed prior to conducting the procedure,
  • Document the requirements in a Standard Operating Procedure (SOP).

SOPs can be set up for a standard procedure but using different chemicals at different times (such as distillation of flammables), or for a particular chemical, or for a group of chemicals. Example SOPs can be found here on the EH&S web site and a more complete description of the SOP development process can be found in Section 6 of the University of Washington Laboratory Safety Manual.

Assessing Routine Tasks in a Shop, Non-Chemical Lab or Similar Work Area

Assess the tasks thoroughly by making use of the knowledge and experience of those performing the task most frequently. Actual steps include:

  • Select the task to be performed,
  • Break the task down into steps,
  • Identify the hazards in each step, For chemical hazards, assess whether a less hazardous chemical can be used or if a lesser amount of the chemical can be used to accomplish the task.
  • Determine safety measures required to reduce the risks from the different hazards to an acceptable level,
  • Document as a Job Hazard Analysis (JHA, also called a Job Safety Analysis or JSA). An example JHA can be found here (pdf) and here is a JHA template in Microsoft Word (doc).

When identifying the hazards in each step, ask yourself or those who perform the task most often as many leading questions as possible, such as "Is this step always done in the same place? If it is done outdoors, how does weather or darkness affect it? Do the people doing this always have access to the same chemicals and equipment?" etc.

Documents:

If chemical protective gloves, goggles, or clothing, are necessary to provide protection, the use of the personal protective equipment (PPE) also has to be documented as a certification for PPE as described in APS 10.4 Personal Protective Equipment and supporting web documents.

Assessing New or Infrequently Performed Tasks

Occasionally, University employees may be required to perform hazardous new or non-routine tasks such as making a confined space entry, performing some scheduled, infrequent, major repair or maintenance task, or scaling-up a new chemical process involving chemical hazards. Prior to starting work on such projects, individual departments or organizational unit supervisors should:

  • Specify and define the unusual task(s) and the steps inherent in the work to be done,
  • Identify all potential chemical, physical, radiological, and biological hazards that you and others familiar with the steps can imagine (categories of chemical and physical hazards are listed in Appendix B. HazCom Training Categories (pdf)), If the process involves large amounts of highly toxic, reactive, flammable, or explosive chemicals (chemicals listed Appendix A of WAC 296-67, with pounds exceeding the threshold quantity) you must follow the formal methods for identifying hazards in as found in WAC 296-67 Process safety management of highly hazardous chemicals.
  • If the task involves lesser amounts of highly dangerous materials or does not involve one of the chemicals listed in WAC 296-67 Appendix A, continue the assessment by researching the potential hazards and how the work was done at other times,
  • Assess whether the hazards may result in exceptional risks and devise methods to minimize the risks to an acceptable level. As part of this assessment, assess whether a less hazardous chemical can be used or if a lesser amount of the chemical can be used to accomplish the task.
  • Document the hazards and planned procedures, and
  • Provide information and training about the proposed work to involved employees, and revise the plan as necessary if they identify problems with the proposed work.

Information should cover specific chemical hazards, protective/safety measures to be taken by employees, and the steps which were implemented to lessen the hazard potential of the operation. Document as a Job Hazard Analysis (JHA) unless working in a chemical laboratory, where is must be documented as a Standard Operating Procedure (SOP). Consult with EH&S (206-543-7388) if there are questions about hazards, risks or procedures.

Re-assessing Tasks after an Accident or Incident

Make sure the accident report is entered into the Online Accident Reporting System, which will provide some guidance in analyzing the cause of the accident by virtue of filling out the form. Try as best as possible to identify the actual cause(s) of an accident rather than simply identifying “the last step in the chain of events” leading to the accident. Identify and document any feasible steps you can identify that will reduce chances of a similar accident or incident happening. Contact EH&S at 206-543-7388 for additional advice on conducting an accident investigation as necessary.

If an accident investigation is performed by others, use their findings to help determine the tasks/equipment/training etc. that can be changed to reduce the chances of a similar accident occurring. If you know of other units performing the same procedure, please notify them of the improvements you have made in the process.

Update the procedural documentation as necessary, such as in a Standard Operating Procedure (SOP), Job Hazard Analysis (JHA) and departmental health and safety plan.

Potential Situations Which Could Impact Any UW Employee

Assessing chemical hazards that could possibly affect any UW employee probably will be done by EH&S or another responsible department, who will provide advice for the entire University. This category of evaluation is meant to address exposures arising out of a situation where a person comes to work and is unexpectedly exposed to materials not part of that person’s assigned duties. Examples of such situations include:

Documentation of the desirable response actions and any training which should be taken in anticipation of such possible hazards is best included in each department’s health and safety plan and in UW programs specific to such situations.